Thank you for this opportunity to comment on the draft environmental impact statement (DEIS) for the citywide mandatory housing affordability (MHA) program. The Capitol Hill Renter Initiative is a grassroots group of 354 renters living on Capitol Hill, supported by staff from Capitol Hill Housing, committed to addressing our neighborhood and city’s affordability challenges. Eighty percent of residents in our neighborhood rent their housing, but for too long renters have been left out of neighborhood decision making that affects our future. This exclusion is especially true for issues like land use policy and environmental review that are highly technical and time-intensive.

It is with this history in mind that our 31-member MHA working group reviewed the 462-page draft DEIS report. We provide the following comments on several aspects of the DEIS, including zoning alternative choices for our neighborhood, the zoning alternative philosophy citywide, the housing and socioeconomics analysis, and other areas where we feel the impacts analysis can be improved.  We hope you will consider these comments when completing the final environmental impact statement (FEIS).

 

Zoning Alternatives in Capitol Hill and Adjacent Urban Villages

Below we provide fine-grained feedback on zoning proposals for the urban villages where we live including Capitol Hill, Pike Pine, Madison-Miller, and 12th Avenue.  This feedback reflects personal and collective knowledge of the intimate details of our neighborhood, which we hope will be of use in the EIS process.

Capitol Hill Urban Village

For the Capitol Hill Urban Village, we generally prefer the zoning changes proposed in Alternative 2.

Alternative 2 is distinguished by a larger upzoned area, from lowrise to midrise, east of Broadway.  This upzone would lead to a higher level of affordability requirements, M2, that would help preserve the economic diversity that we love about our neighborhood.  Across the entire Capitol Hill-First Hill Urban Center, Alternative 2 would result in 1,267 new affordable units, rather than only 819 new affordable units under Alternative 3.  Alternative 2 will also have the benefit of allowing more housing overall in the Capitol Hill Urban Village.

We believe that the area east of Broadway is an appropriate place for growth with access to light rail and frequent bus service, walkable streets with stores and services, and proximity to jobs in Downtown and South Lake Union.  The urban village includes great schools from elementary (Lowell) to college (Seattle Central) and great community open spaces from Cal Anderson to our many new pocket parks.  These are just some of the many factors that led the City to designate this urban village “high opportunity.”

Our neighborhood has ample experience with midrise as a zoning category and we like how it has performed west of Broadway. Contrary to the perception of some unfamiliar with midrise zoning, on Capitol Hill the area currently zoned midrise is notable for big beautiful trees and a human-scaled, granular development pattern.  Midrise zoning allows for lots of apartment buildings for renters to live in and maximizes our building codes capacity for low cost wood frame construction that can contribute to affordability as acknowledged in the Housing and Socioeconomics section.

While the Capitol Hill Urban Village is designated as high displacement risk, the area being upzoned is relatively high income with a median income of $63,419 (US Census Tract 75, ACS 2011-15). The higher displacement risk parts of the Capitol Hill Urban Village are already zoned midrise.  Adding more capacity in the eastern portion of the neighborhood will help relieve development pressure on other parts of our neighborhood and the city, areas where the residents are more genuinely at high risk of displacement.

We are disappointed that the urban village boundaries cannot be extended further north to Volunteer Park and east to Madison-Miller.  We believe this could allow for a more gradual step down in heights and greater economic and social integration of the wealthy mansion blocks immediately outside of the urban village boundaries.  It could also give more people access to great amenities such as Volunteer Park, Interlaken, and Lowell and Stevens Elementary.

While we support the changes to midrise in Alternative 2, we also believe the city should accompany them with increased investments in quality of life in this area.  Investments such as pocket parks, street trees, and walkability improvements will help the neighborhood accommodate the projected growth while mitigating the biological and open space impacts.

Pike Pine Urban Village

Both Alternatives 2 and 3 generally treat Pike Pine the same.  Our main concern for Pike Pine is in regard to the impact on the Pike Pine Conservation Overlay.

The Conservation Overlay has been a successful tool for accommodating growth while preserving and enhancing human-scale neighborhood character among pre-World War II commercial and mixed-use buildings.  This success includes the retention of character structures as well as a unique set of zoning and design guidelines that incentivize smaller building footprints and storefronts.  We believe that similar regulations could help mitigate concerns discussed in the historical resources section, especially regarding business corridors, not just on Capitol Hill, but around the city, such as the Ave.

Despite its success as a voluntary incentive program, the Overlay is at risk from the Mandatory Housing Affordability zoning changes.  When the base zoning in most of the Pike Pine Urban Village moves from 65 feet to 75 feet, the value of an additional 10 feet of height will be reduced.  Without other actions, in many cases the incentive will no longer be sufficient to cover the cost of character structure preservation.

We believe that a solution can be found that both preserves the effectiveness of the Overlay and incorporates MHA in Pike Pine.  We hope that the City of Seattle will continue to work with the Pike Pine Urban Neighborhood Council’s process to refine the base zoning and incentives in Pike Pine so that both programs can work effectively together.  We also support proposed changes to building code requirements that would reduce the cost of construction at 85 feet by allowing 6 stories of type IIIA wood frame construction over two stories of type I concrete construction.

12th Avenue Urban Village

Alternatives 2 and 3 are almost identical for the 12th Avenue Urban Village.  We believe both alternatives miss a valuable opportunity to increase heights and ground floor retail adjacent to the Madison Bus Rapid Transit Corridor.

In particular, we believe that M1 affordability requirements and zoning change from LR3 to NC3-75 would be most appropriate in the area south of Union Street between 13th and 14th Avenues, an already high foot traffic area with commercial uses on the north side of Union St.  This area also includes property owned by non-profit affordable housing providers such as Capitol Hill Housing and the First AME Church Housing Corporation that could use the added development capacity to produce more affordable units.  In addition to added housing capacity, NC3-75 zoning would allow these non-profits to provide affordable space for culturally relevant businesses and social service providers.

Madison-Miller Urban Village

We are generally more supportive of the zoning changes proposed in Alternative 3 for the Madison-Miller Urban Village.

As identified in the DEIS, Madison-Miller is a very high opportunity Urban Village.  It has great transit service to jobs in Downtown (bus routes 11 and 12), South Lake Union (8) and the U District (48).  Madison-Miller is close to great schools (Meany, Stevens, St Joes, Holy Names), parks and open space (Miller Playfield, Volunteer Park, Interlaken, Washington Park Arboretum), and a fantastic community center.  This neighborhood provides a welcoming home for many families with kids and the added lowrise zoning will allow townhouses a more moderate-cost family housing option.  As fewer households have large yards, the city should mitigate the loss of these play spaces by finding ways to slow traffic and create more play streets.

Madison-Miller is already home to several affordable housing properties that help keep this part of our neighborhood economically and racially diverse.  These buildings are a great asset for our community because they protect their residents from the risk of displacement.  Alternative 3 would result in 177 new affordable units rather than only 133 under Alternative 2, and far more than Alternative 1.  This is true not only because increased development capacity will allow for more on-site performance of affordable housing, but also because it will create more zoning under which the Seattle Office of Housing can make cost-effective investments leveraging federal low income housing tax credits.

The arrival of new residents can spur concerns about insufficient parking.  We believe that Madison-Miller deserves its own restricted parking zone (RPZ) to better manage on-street parking.  We also hope that the Seattle Department of Transportation will continue to look at reforms to the RPZ system that address oversubscription, which can make the zones ineffective.

Finally, we do not support the M2 changes from single family to LR3 just east of Miller Park.  We believe an M1 change to LR2 would be more appropriate given the location adjacent to the edge of the urban village.  We are disappointed that an urban village boundary expansion is not being considered for the areas immediately north, west, and south.

Beyond the Existing Urban Village Boundaries

While we understand that none of the urban villages in our neighborhood is being considered for boundary expansion, we believe this is a mistake. The current boundaries, in light of the many changes since 1994, today feel restrictive, arbitrary and unfair in many cases. The boundaries create donut holes between our urban villages and leave out some of the wealthiest areas most equipped to accommodate growth without risk of displacement. In the long run, we hope the City will consider including upzones and mandatory housing affordability in these areas. If more areas had been included in the current process, the same housing production goals could have been accommodated with more modest changes within the existing urban village boundaries.

Zoning Alternatives Citywide

We generally prefer the zoning changes suggested in Alternative 3. We state this preference acknowledging that we prefer Alternative 2 for the Capitol Hill Urban Village itself, which we believe is somewhat miscategorized as high displacement risk, especially in the portion of the urban village designated for larger zoning changes. Even if the DEIS displacement analysis does not show that increased development results in increased displacement, we still think it is safer to focus more growth in areas with lower risk of displacement. Our one overriding disagreement with the Alternative 3 framework relates to the urban village boundary expansions. We believe that such boundary expansions are an unmitigated good and that the maximum boundary expansions, with zoning changes to at least residential small lot, should be included in the Preferred Alternative of the FEIS.

Greenhouse Gas Emissions and Climate Impacts

We believe that the DEIS understates the climate change benefits of Alternatives 2 and 3 relative to Alternative 1.  As the analysis notes on page 448:

“While the variation among the alternatives’ projected emissions in Seattle is minor, the same amount of growth in other jurisdictions in the area would result in very different results…. VMT per population/job is nearly 55 percent higher outside of Seattle [] than inside Seattle. This suggests that the same amount of development outside Seattle would result in substantially higher emissions since 2035 fuel economy would remain equivalent across jurisdictions.”

We expect that vehicle miles traveled (VMT) per person and job is even lower in Seattle’s urban villages, where MHA will add the most capacity, than in the rest of the city.  Furthermore, we know that in some cases, added density in urban villages can lead, not just to relatively fewer emissions, but also to absolute reductions in transportation emissions, as frequent transit service becomes more viable and more goods and services locate within walking and biking distance of more people.

Seattle enjoys similar climate benefits with regards to energy use in buildings relative to our suburban neighbors.  The additional multi-family buildings allowed through MHA, by their geometry, have a lower surface area to volume ratio than suburban single family homes, making them easier to insulate, heat, and cool. People living closer together are also more likely to share resources, reducing greenhouse gas emissions from consumer goods. Overall, the FEIS should better reflect the full climate change benefits of citywide MHA.

Housing and Socioeconomics

Of all the issues addressed in the Affected Environment, Significant Impacts, and Mitigation Measures section of the DEIS, we believe the Housing and Socioeconomics analysis is the most important and deserves special attention in our comments. MHA should be designed to maximize affordability and minimize displacement. The DEIS analysis can help the City determine the best Preferred Alternative for achieving these goals. We believe there are several areas in which this analysis could be significantly improved.

Getting the Subsidized Affordable Housing Data Right

This section conducts a regression of housing production relative to loss of low income households and finds that increased production in a neighborhood reduces the loss in that neighborhood. However, as noted in the analysis, the DEIS lacks comprehensive, comparable data on subsidized affordable housing (page 150). The inadequacy of data on affordable housing investments and lack of adjustments for the impacts of those investments undermines the credibility of the connection between housing production and preventing displacement. For example, South Lake Union is highlighted as an example of a neighborhood that both produced large quantities of new housing and increased the number of low income households (page 153). This ignores the massive investments in affordable housing made in South Lake Union by the Office of Housing over the last decade to achieve this outcome. Not only will including subsidized affordable housing data make the analysis more credible, it will also make the analysis more relevant to MHA. The true question the DEIS should be asking is what will the impacts be of increased housing development and increased investment in subsidized housing.

The Federal Department of Housing and Urban Development (HUD) data that was used does not include low income housing tax credit (LIHTC) funded projects unless the LIHTC projects also received direct HUD subsidies (page 150).  To correct this, the FEIS should, at a minimum, include HUD’s LIHTC database as well. Addresses should be tracked in each dataset to prevent double counting of projects with both LIHTC and direct HUD funding. Preferably, these HUD data sources should be replaced by more comprehensive Seattle Office of Housing data that are already available and presented for 2016. MFTE units, which do not receive either HUD or LIHTC funding, should also be included. Additionally, Hope VI sites should be excluded from the regression analysis. Many of the outliers in the regression analysis appear to be Hope VI sites that have unique affordability and development trajectories during the study period.

Addressing Race and Racial Displacement

The displacement analysis also fails to look at displacement by race. Racial displacement, regardless of the connection to income, should be a concern for the City given the history of racially biased land use policy in Seattle and the US generally. People of color have too often been displaced and excluded from many parts of our city, including Capitol Hill. Furthermore, race, unlike income, does not change for a person over time. A neighborhood can lose low income households because previously low income people achieved greater economic success. In contrast, the loss of a particular racial group can mean only the loss of people from that group. An analysis of racial displacement should be added to the FEIS.

The Displacement Risk Index and Double Counting

Much of the DEIS displacement analysis relies on the Displacement Risk Index.  The Displacement Risk Index, developed for the Seattle 2035 Comprehensive Plan update, assumes that neighborhoods with more zoning capacity for new housing are at greater risk.  The DEIS then finds that more zoning capacity does not increase displacement risk, while simultaneously relying on an index with a contradictory assumption.  This leads to circular conclusions such as the finding that higher displacement risk urban villages are more likely to experience more development (page 149).  They are more likely to experience more development because development capacity is part of the criteria for being high displacement risk.  While we do not believe that the FEIS should be required to develop a new displacement risk index, we do think it should acknowledge the inherent contradiction in assumptions.  Eventually, the displacement risk index should be updated to be agnostic regarding the displacement impacts of zoning.

We appreciate that the displacement analysis was conducted separately for the different urban villages by the displacement risk and opportunity access categories.  However, the DEIS should look at the displacement risk of these urban villages at the beginning of the study period, in 2000, not today.  These urban villages are categorized as high displacement risk today in part because they have more low income people.  It is therefore not surprising that low income people were more likely to move to these urban villages over the past 10 years.  Again, this logic is circular and undermines the credibility of the findings.  While a new displacement risk index for the year 2000 should also be outside the scope of the FEIS, the causation problems in this analysis should at least be acknowledged. (page 155)

The Benefits of a Coordinated Citywide Upzone

The citywide MHA process is unique in Seattle’s recent history.  It has been a long time since Seattle has made zoning changes that affect so many parts of the city.  Instead, Seattle has tended to upzone individual neighborhoods one-at-a-time.  Some of the most consistent findings connecting increased development capacity to lower housing prices, referenced in the appendices, are based on findings at the regional level.  When an individual neighborhood receives an upzone, the regional capacity implications are generally small and the benefits of increased supply are less likely to be felt.  Instead, the main effects come from the increase in new housing, which is generally more expensive.  By changing this pattern and upzoning citywide, the benefits of the regional increase in housing capacity are likely to be more tangible. The FEIS should take this benefit into account and distinguish between the affordability and displacement impacts of changes in one neighborhood and the impacts of simultaneous changes in many neighborhoods.

This distinction can be seen in the impact on land values.  The DEIS notes that upzoning a particular parcel can increase that parcel’s land value (though also decrease the land costs per housing unit).  What the DEIS does not acknowledge is that upzoning many parcels at one time can diminish the increase in land value of each individual parcel by making the increase less rare.  A broad citywide upzone, therefore, is likely to increase land values less than a small neighborhood upzone. (page 162)

Types of Buildings

We appreciate that the DEIS acknowledges that certain construction types are more expensive than others and estimates which alternatives will allow more construction of each type by looking at the capacity within zoning categories. Alternatives 2 and 3 allow significantly more development of low cost wood frame construction in residential small lot and lowrise zones, a component of these alternatives that should contribute to affordability.  This analysis would benefit from breaking apart midrise and highrise capacity. While both require construction costs higher than lowrise projects, midrise construction is still mostly wood frame, while highrise construction is entirely concrete and steel.  (pages 160-163)

Tenant Relocation Assistance

As renters, we know the burden of being forced to move.  As rents go up on Capitol Hill, many of us are on the brink of being priced out of the neighborhood.  The tenant relocation assistance data shows the limitations of the Tenant Relocation Assistance Ordinance (TRAO) and indicates the greater need to address economic displacement.  Only 698 households were eligible for assistance between 2013 and 2016 (page 145). The increased development under Alternatives 2 and 3 is expected to result in, at maximum, 76 additional households displaced by demolition (page 172).  Partially, this data reflects the unfairly strict income and household thresholds of the TRAO.  However, this data also reflects the small scale of direct displacement from demolition relative to economic displacement.  Economic displacement appears to be much more widespread with fewer remedies.  Low income households experiencing economic displacement deserve access to relocation assistance as well as more focus in the DEIS.

Direct displacement from demolition and economic displacement are also distinguished by where people go after they are displaced. Demolition or renovation does not inherently imply that a household can no longer find housing in that neighborhood.  In contrast, when a household must move because of rent increases, other rents in that neighborhood are also likely to have increased, resulting in displacement not just from a particular unit, but from an entire area of the city.  Unfortunately, the DEIS displacement analysis acknowledges that it does not look at where people go after they are displaced, an important component of fully understanding the problem.

Regional Data and More Recent Data

The economic displacement analysis compares the City of Seattle to the Rest of King County.  A comparison to the metropolitan region would be more appropriate.  Anecdotally, we hear that middle and working class people are getting pushed out of all of King County and moving increasingly to Pierce, Snohomish, and Kitsap Counties.  Looking at household data at this regional scale would provide a better understanding of where lower income households are going when they leave Seattle.  (page 148)

The data comparison in this section is for 2000 to 2009-2013 (effectively 2011).  This period is one of remarkable stability in rental housing cost relative to the following period 2011-16, when rents spiked upwards.  More recent data, such as the 2011-15 American Community Survey and city and county-wide data from the 2015 American Community Survey would be more relevant to our current affordability challenges. (pages 148-151)

Conclusion

Seattle’s affordable housing crisis requires rapid responses including speedy implementation of citywide mandatory housing affordability.  Our comments are not intended to delay the DEIS process.  In fact, we have taken care to identify several of our criticism as beyond the scope of the EIS in order to prevent unnecessary delays.  We hope that our comments on the DEIS will help inform an effective FEIS and Preferred Alternative, as well as future thinking about how we analyze the impacts of land use decisions in our city.  We look forward to engaging with the remaining final steps towards implementation.

Sincerely,

The Capitol Hill Renter Initiative

The Capitol Hill Renter Initiative is a group of community members committed to addressing the neighborhood’s affordability and mobility challenges and advancing the voice of renters at City Hall. People interested in getting involved with the Renter Initiative can check out the “Capitol Hill Renter Initiative” on Facebook or by visiting this page.

The Renter Initiative is a project of the Capitol Hill Eco District and staffed by Capitol Hill Housing. The views expressed represent those of Initiative members and not necessarily Capitol Hill Housing or the EcoDistrict.

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